Key points at a glance

• The regulation: The EU short-term rental regulation has applied since 20 May 2026. It does not ban holiday apartments, but it gives authorities monthly data on every registered unit.
• Berlin: The city missed the start date and still checks applications before issuing a number. That does not comply with the regulation and is likely to end up before an administrative court.
• Politics: Since 20 September, Die Linke has been the strongest party with 25.7 percent and is negotiating with the Greens and the SPD. Its programme calls for a comprehensive ban on holiday apartments in residential buildings.
• The market: Berlin has lost more than 1,000 active Airbnb listings in two years, around 15 percent. What remains are professionally managed, legally compliant units.

Berlin, November 2026. Anyone running holiday apartments in this city faces two developments at once: new rules from Brussels and a Senate that is moving clearly to the left after the election. The regulation delivers the data that authorities previously lacked. Die Linke's election programme says what is to be done with it.

1. The EU regulation: first the number, then the checks

Regulation (EU) 2024/1028 has applied directly since 20 May 2026, including in Berlin. With the Short-Term Rental Data Exchange Act (KVDG), the federal government has made the Federal Network Agency the central body to which platforms submit their data.

Three things are regulated. First, a uniform registration procedure for hosts wherever a municipality requires registration. Second, obligations for platforms: Airbnb, Booking.com and all others must request the number and display it in the listing; without a number, nothing gets listed. Third, a monthly data exchange in which nights rented, number of guests, address, number and listing URL are sent to the responsible municipality for each unit.

The regulation does not ban holiday apartments. Article 2 leaves housing and planning law untouched, and Berlin's ban on the misuse of residential space remains as it is. But it is the tool municipalities can use to enforce what has long been on paper.

The core is the registration number. Under Article 5, hosts provide, among other things, the address, type of accommodation, maximum number of guests and permit status. Article 4(3) requires an online procedure in which the number is issued automatically and without delay. Checks under Article 6 only come afterwards, up to suspending the number and removing the listing. A registration number is therefore not a permit.

2. Berlin: a missed start and old reflexes

Berlin has had a registration requirement since 2018; every host knows the Registration number Berlin in the listing. Even so, the city was not prepared. By 20 May 2026 the procedure should have been adapted: online, automatic, not tied to a permit. Berlin missed this deadline.

There is now an online service for the new Berlin registration number, but so far only for private individuals. Companies still apply for their Berlin holiday apartment registration number in writing at the district office.

Our main problem is the logic behind it. The Berlin procedure was never a pure registration but a disguised permit procedure: only those renting out their main residence or presenting a change-of-use permit received a number. Berlin is sticking to this, and the authority continues to check documents before issuing a number. The regulation allows asking about a permit, but requires automatic issuance and moves the checks to afterwards.

Registration thus becomes a barrier to market entry. Anyone waiting months for their number may not list during that time. This also affects entirely legal offers: units in commercial buildings, approved existing apartments, buildings that were never residential space. We expect this question to end up before an administrative court.

3. After the election: what Die Linke plans for holiday apartments

In the Berlin House of Representatives election on 20 September, Die Linke became the strongest party for the first time with 25.7 percent, clearly ahead of the CDU with 18.8 percent. Since 2 November it has been negotiating a coalition with the Greens and the SPD; Elif Eralp wants to become Governing Mayor.

Housing was its central issue, and holiday apartments are one of its most visible targets. The election programme calls for “a comprehensive ban on holiday apartments in residential buildings”. This does not only mean illegal offers; it would hit approved units just as much. Digital tools are to help authorities find illegal offers and return the apartments to the rental market. Brussels is supplying these tools: since September, platforms have been reporting their data to the Federal Network Agency.

On top of that come a ban on furnished short-term living in all social preservation areas, which also affects business with fitters and project staff, a state office for tenant protection and more staff in the housing offices. So far, the ban on misuse of residential space has failed mainly because of a lack of staff. Exactly this bottleneck is to disappear.

How much of this ends up in the coalition agreement is open. The direction is not. Unlike in 2016, a red-green-red Senate now learns every month which apartment is rented out how often.

4. The market is shrinking: what this means for owners

The number of active Airbnb listings in Berlin already shows the change. In November 2024 there were around 8,500, in January 2026 still 8,300, in October 2026 about 7,200. That is more than 1,000 fewer listings in two years, a decline of around 15 percent. The drop begins where the regulation took effect.

We expect the trend to accelerate. Offers without a valid number will disappear from the platforms, and the rest will come under pressure through the data. Anyone renting out on the side without permit documents, registration and clean city tax accounting will drop out or be pushed out. The holiday apartment as an after-work project is over in Berlin.

Anyone who can legally use an apartment as a holiday rental should look for a professional partner now. GreatStay has been doing this since 2014 and, with GreatStay Co-Hosting, is one of the most experienced providers of Airbnb co-hosting in Berlin. We check the permit status of every unit, apply for the new registration number, maintain the listings, pay the city tax and document everything so that it stands up to any inspection. As an Airbnb co-host in Berlin we take over the entire operation; the owner remains the owner and receives their statement.

Transparency is no enemy to those who work properly. It only makes the field smaller. Anyone who runs co-hosting in Berlin seriously will hold their own in this smaller field.

Sources

Regulation (EU) 2024/1028 on EUR-Lex; German Holiday Home Association (Deutscher Ferienhausverband), FAQ on the EU regulation; ApartmentAllianz Berlin, new EU registration for holiday apartments; Die Linke Berlin, election programme for the 2026 House of Representatives election; Berlin Service Portal, registration number.